One of the quandaries I find with the “Safe HW Area” approach is those areas that are actually set up as weld shops with all the bells and whistles we want in welding shops, such as ventilation to control exposures resulting from welding, cutting, and grinding.  For example… 1910.252(a)(2)(viii) Ducts, requires that any ducts and/or conveyor systems that might carry sparks to...

The Minnesota Department of Labor and Industry’s (DLI’s) Minnesota OSHA (MNOSHA) Compliance has issued a $621,600 penalty to a trucking company primarily for lack of confined-space safety requirements at its facility in Virginia, Minnesota, following a worker fatality in a tanker in March 2024. In July 2024, MNOSHA Compliance issued 10 serious citations for violations of the general industry,...

In 2017, FRA published a report on safety culture sponsored by the U.S. Department of Transportation’s (DOT) Safety Council. The report states that when safety culture is strong, there are less frequent and less severe accidents. DOT defines safety culture as the shared values, actions, and behaviors that demonstrate a commitment to safety over competing goals and demands and cited the following ten...

The critical issue is that a proposed change’s direct and indirect effects on the control of hazards should be identified and assessed. Due to the greater potential consequences of an accident, major accident hazard sites should aim for greater reliability in their planning and decision-making. Avoid too many simultaneous changes, which may result in inadequate attention to some or all—phase...

The FMCSA has begun Phase III of a project to refine the non-destructive metallurgical testing method and protocol for detecting cracks in nurse tanks and to determine possible relationships to causal factors not previously considered in detail. Background: … HomeRead More »

Culture can best be understood as “the way we do things around here.”  An organization’s culture will influence human behavior and performance at work. Poor safety culture has contributed to many major incidents and personal injuries. Success typically comes from: good leadership, good worker involvement, and good communications. Creating a positive safety culture in an organization...

I have seen some crazy videos this year of just unreal worker behaviors. The ones that shock me to my core are what I would call “horseplay.” These are the times workers need to be terminated. I may go as far as issuing discipline to those watching/taping and even up the ladder to supervisors and managers responsible for the workers and/or where the behaviors occur. But I will spare the supervisor...

On February 23, 2023, at 11:45 a.m., an employee working for a city water department was repairing a leaking 12-inch PVC waterline main valve. The valve was located in a utility vault approximately 5 feet deep. The employee turned off the water to the west of the valve by opening multiple fire hydrants. He and a coworker closed the valve, stopping the water from flowing. The employee did NOT turn the...

Sometimes, this government wears me out. A friend and I had this discussion last week about Chemical Container Labeling. The standard is VERY CLEAR (for those who take the time to read it). It comes down to the following: 1910.1200(f)(1) Labels on shipped containers vs 1910.1200(f)(6) Workplace labeling So the first sentence in OSHA’s newest Quick Card is flat-out WRONG.  Here are my previous...

OSHA’s current age-correction table, Appendix F, discontinues at age 60. More people are working into their sixties instead of retiring, and there is no adequate way to assess presbycusis (age-related hearing loss) in these workers using the current OSHA table. OSHA’s age-correction tables were based on a small sample size and research from the 1970’s. You advocate for the use of...

OSHA clarifies HAZWOPER training requirements for on-scene Incident Commanders and other positions in the Incident Command System (ICS) and whether previous non-HAZWOPER training can be credited toward the training required by HAZWOPER for Incident Commanders.  Here are the four (4) questions OSHA discusses: Is it OSHA’s intent that Incident Commanders be 24-hour HAZWOPER trained, irrespective...

A client recently underwent an RMP inspection by the US EPA.  One of the issues the inspector took issue with was that the facility did not “certify” their 3-year audit.  This stems from the following: (emphasis by me) EPA RMP § 68.79 Compliance audits(a) The owner or operator shall CERTIFY that they have evaluated compliance with the provisions of this subpart, at least every...